On March 26, 2021, OSAI’s Board of Directors approved for the first time the adoption of the Management and Control Organizational Model in accordance with the references of Legislative Decree No. 231/2001, which introduced into our legal system the criminal liability of corporations for administrative offenses dependent on crimes committed by individuals in the interest or to the advantage of those corporations. Legislative Decree No. 231 has revolutionized the principles relating to the criminal liability of companies in that, today, a company without an Organization, Management and Control Model can be exposed to heavy consequences for crimes committed within it, ranging from significant fines to disqualification from conducting business; exclusion from facilitations, financing, contributions or subsidies and the possible revocation of those already granted; and the suspension or revocation of authorizations, licenses or concessions functional to the commission of the offense.
OSAI’s Organizational Model 231 is part of a set of procedures, organizational provisions, and codes of conduct that regulate and define the company’s structure and the management of processes that are sensitive to the commingling of possible crimes in the making of the Company. Since there is no generic model applicable for all companies, it was drafted according to the specific activities, production processes and interlocutors with which OSAI interacts involving all company actors.
In addition, the activity of controlling the observance and implementation of the Organizational Model 231 is entrusted to a Supervisory Board (SB) composed of three members external to the company, which periodically receives information flows regarding the model itself in addition to keeping under control the training and information initiatives for the dissemination of knowledge but, above all, understanding of the model itself within the company. The OSAI SB is currently composed of Dr. Giulio Tedeschi (Chairman), Lawyer Andrea Cammarota and Dr. Domenico Laterza.